ITAT Delhi held that assessments under Section 153C were invalid as the Assessing Officer failed to record satisfaction in terms of the amended statutory requirement. The Tribunal quashed the assessments for lack of proper jurisdictional compliance.
The Delhi ITAT held that activities relating to environmental protection, farming awareness, and sustainability education qualify under the preservation of environment limb of Section 2(15). The Tribunal ruled that such activities are not hit by the restrictive proviso applicable to general public utility cases.
ITAT Delhi held that if Government money was fraudulently routed through the assessee’s account by another person, such deposits may not constitute the assessee’s income. The case was remanded for factual verification.
ITAT Delhi condoned a 333-day delay in filing appeal after finding the reasons stated by the assessee to be bona fide. The matter was remanded to the CIT(A) for fresh consideration.
ITAT Delhi held that Section 69A could not be invoked where the Assessing Officer himself accepted that transactions were recorded in the books of account. The matter was remanded for limited verification of sales records and related documents.
ITAT Delhi held that effective opportunity of hearing was not provided before passing ex parte assessment and appellate orders. The matter relating to sustained addition was remanded back to the Assessing Officer for fresh adjudication.
The Tribunal held that differences between customs assessable value and invoice value cannot automatically justify additions under Section 69C. The ruling clarifies that actual unexplained expenditure must first be proved by the Revenue.
ITAT Delhi upheld deletion of disallowance under Section 40A(3) after finding that payments were made to multiple labourers and no individual payment exceeded statutory limit. Tribunal accepted that bulk transfers were only administrative in nature.
ITAT Delhi confirmed deletion of addition on alleged diversion of interest-bearing funds, holding that hypothetical or notional income cannot be brought to tax. The ruling relied on the principle that only real income is taxable.
The ITAT Delhi held that an assessment order passed in the name of an amalgamated company that had ceased to exist was void ab initio. The Tribunal relied on settled law that jurisdictional defects involving non-existent entities cannot be cured under the Income Tax Act.
